Facing a storm can be daunting. As we close 2014 and welcome in 2015 CMS, the OIG, your commercial payers, all have their sites on your bottom line. CMS will surely revive rack RAC and the OIG predicts millions to be recovered in the audit of “canned documentation”. So storms can be rough in this next year will likely test your facility. But there are ways to prepare.

Your audit plan

if your site doesn’t have an audit plan including a comprehensive internal third-party audit policy go to the homepage or the contact page and will be happy to send you a free generic internal audit policy. These can be crucial in that they give the facility a measure of control over the third-party audit firms. It is always a shock to our firm when we do a site survey and discover that someone in medical records is signing off on audit findings without doing a review of the record alongside the third-party auditor. This is asking someone who makes their income based on the refunds they collect to be honest enough to not cheat this process. If this is the case at your site a simple review of the case by someone will likely find discrepancy between the Third Party Firms finding and your facilities billing and documentation practices.

Compartmentalize your auditing

Almost every site we’ve ever worked for starts like this. There is an auditor for commercial audits, a coder generally looks at DRG and APC Validation, someone in the business office will likely handle denials. Problem is these three never share data on what can fairly be called audits. Any review that effects your bottom line is an audit. As such, it should be handled like an audit and this is where your audit policy comes into play.

The Audit Policy

Your audit policy should serve as the first line of defense for your facility. Your audit policy should require a letter of intent, an audit fee, and guidelines for how your site conducts an audit. Any review that affects the bottom line should be treated as an audit. This means we don’t send records by mail to a firm that wants to audit. We require that firm to come on-site for everything from a commercial defense audit to a DRG validation. For a look at our generic policy go to the contact page of this site and will send you one for free.

RAC reviews

While they’ve made plenty of trouble for themselves with their settlement offer that seems to have gone sideways in the contracting issues that they’re settling in court CMS has much to do but any firm making billions of dollars is going to sort through those problems and get this process up and running again. Likely sooner than later. There are excellent RAC tools such as RACTelligence which can be found on our co-op resources page. These tools assist the auditor in capturing deadlines and data that help define why losses occur. They also capture crucial data such as due dates an appeal information.


You’ll find when you consolidate your auditing departments and you bring the audit plan and policy and data capture under one person’s responsibility that the losses associated with FTE hours and refunds are staggering. It is only through analytics and committee meetings carefully planned and delivered information can go to the biggest offenders, changes can be made to the CDM, and changes can occur within the billing process. This is also very fertile ground for education and training as every error becomes very evident. To learn more about how to save millions contact Medlinks Cost Containment on our contact page.

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Free Audit Policy

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